ARTICLE · 21 APRIL 2015

Taxation Of Belgian Commuters

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The remuneration is not borne by a permanent establishment which the employer has in the State of employment.

LuxembourgTax

Bonn Steichen & Partners

The double tax treaty signed on September 17^th 1970 between the Grand-Duchy of Luxembourg and the Kingdom of Belgium (the “DTT”) provides in its article 15 that employment income derived by a resident of a contracting State in respect of an employment exercised in the other contracting State is in principle taxable in such other contracting State. However, in case the link between the employee and its State of employment is weak, the exclusive taxing right falls back to the State of residence. Such weak link is deemed to exist, in case three criteria are cumulatively fulfilled:

The employee is present in the State of employment for less than 183 days in an aggregate 12-month period commencing or ending in the fiscal year concerned;

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